DCL-07-034, Commitment Change Summary Report

Commitment Change Summary Report

ML070930432
Person / Time
Site:	Diablo Canyon
Issue date:	03/28/2007
From:	Becker J Pacific Gas & Electric Co
To:	Document Control Desk, NRC/NRR/ADRO
References
NEI-99-04, PG&E Letter DCL-07-034, SECY-00-0045
Download: ML070930432 (7)

Text

! ElectricCompany' PacificGas and James R. Becker Diablo Canyon Power Plant P. 0. Box 56 Vice President Diablo Canyon Operations and Avila Beach, CA 93424 Station Director 805.545.3462 March 28, 2007 Fax: 805.545.4234 PG&E Letter DCL-07-034 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Power Plant Units 1 and 2 Commitment Change Summary Report

Dear Commissioners and Staff:

In accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0, endorsed by the NRC in SECY-00-0045, Pacific Gas and Electric Company (PG&E) is submitting the enclosed Commitment Change Summary Report for Diablo Canyon Power Plant (DCPP), Units 1 and 2. The report provides a summary of the regulatory commitment changes that occurred during the period January 1, 2006, through December 31, 2006. The summary for each change includes identification of the source document(s), a description of the original and revised commitments, and a justification for the change.

The regulatory commitment changes described in the report were processed in accordance with the NEI guideline, and were determined to not require prior NRC approval. The report does not include commitment changes that are contained in 10 CFR 50.59 evaluation summary reports, or in other submittals previously transmitted to the NRC.

PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter.

Sincerely, James R. ecker SSZ1/R0285223 Enclosure cc: Terry W. Jackson, NRC Senior Resident Inspector Alan B. Wang, NRC Project Manager cc/enc: Bruce S. Mallett, NRC Region IV (2)

A member of the STARS (Strategic Teaming and Resource Sharing) Altiance Callaway e Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

Enclosure PG&E Letter DCL-07-034 JANUARY 1, 2006, THROUGH IDECEMBER 31, 2006 CONTENTS Item Commitment Subject Paqe 1.0 Reactor Cooldown Requirements 1 2.0 Steam Generator Inspection Program 2 3.0 Procedure Enhancements For TES And The REMP 4

Enclosure PG&E Letter DCL-07-034 1.0 REACTOR COOLDOWN REQUIREMENTS Source Document(s)

" Pacific Gas and Electric Company (PG&E) Letter DCL-81-1207, dated December 7, 1981, regarding Generic Letter 81-21

• Significant Operating Experience Report 81-04 Original Commitment "Diablo Canyon's operating procedures will be revised to specify a cooldown rate of 25 degrees Fahrenheit per hour and a subcooling margin sufficient to prevent reactor vessel voiding. Diablo Canyon's procedure for natural circulation will be tested during the special low power test program."

Revised Commitment "Diablo Canyon's operating procedures will be written to specify a cooldown rate and a subcooling margin sufficient to prevent reactor vessel voiding in accordance with Westinghouse Owners Group (WOG) Emergency Response Guidelines (ERG) and background documents. Diablo Canyon's procedure for natural circulation was tested during the special low power test program."

Justification for Change When this commitment was originally written, both Unit 1 and Unit 2 were considered Thot plants and thus the cooldown rate per WOG ERGs was 25TF per hour. With the Upflow/Head Temperature Reduction (UHTR) modification, Unit 2 will be considered a Tcold plant and thus, the cooldown rate per the WOG ERGs is 50TF per hour. This value is also confirmed by Westinghouse Letter LTR-PO-05. Unit 1 is still considered a Thot plant and uses the more restrictive cooldown rate per WOG ERGs (25°F per hour).

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Enclosure PG&E Letter DCL-07-034 2.0 STEAM GENERATOR INSPECTION PROGRAM Source Document(s)

" PG&E Letter DCL-98-046, dated March 27, 1998, regarding Generic Letter 97-06

• NRC Generic Letter 97-06 Original Commitment "The frequency of sludge lancing at DCPPUnits 1 and 2 is every refueling outage, at which time it will be verified that the sludge lance equipment can continue to be inserted without interference. If interference with the sludge lance equipment is detected, the lower wrapper support blocks will be visually inspected....

Feedwater nozzle welds and thermal sleeves will be visually and UT inspected on a frequency based on the current feedwater nozzle configuration (i.e., five steam generators have a new integral forged fitting design, and three steam generators have the original standard design) and the degradation rates observed to date. At a minimum, the DCPPinservice inspection plan requires UT inspection of one feedwater nozzle weld every 10 years."

Revised Commitment "Duringeach outage in which sludge lancing is performed, it will be verified that the sludge lance equipment can continue to be inserted without interference. If interference with the sludge lance equipment is detected, the lower wrapper support blocks will be visually inspected....

Feedwater nozzle welds and thermal sleeves will be visually and UT inspected on a frequency based on the current feedwater nozzle configuration (i.e., five steam generators have a new integral forged fitting design, and three steam generators have the original standard design) and the degradation rates observed to date."

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Enclosure PG&E Letter DCL-07-034 Justification for Change The original commitments were made in response to a Generic Letter 97-06 request to discuss programs in place to detect degradation of Steam Generator internals, along with a description of inspection plans, inspection scope, frequency, methods, and equipment.

Relative to the changes to the wrapper drop inspection, there is a low susceptibility of wrapper degradation for Westinghouse designed SGs.

Wrapper degradation reported in GL 97-06 is limited for foreign Pressurized Water Reactor facilities. There is no regulatory or industry requirement to perform sludge lancing during every refueling outage as a means to detect potential wrapper drop. Eddy current examinations are performed every refueling outage, and these results are used to effectively monitor for wrapper misposition. That is, if eddy current inspections detect tube damage in the periphery of the first tube support plate (suggesting possible evidence of wrapper misposition), a visual inspection of the lower wrapper support blocks would be conducted.

The feedwater nozzle weld inspection was originally based on a frequency of one weld every 10 years. These inspections are no longer required based on the recently implemented risk informed inservice inspection program.

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Enclosure PG&E Letter DCL-07-034 3.0 PROCEDURE ENHANCEMENTS FOR TES AND THE REMP Source Document(s)

• PG&E Letter DCL-94-093, dated May 2, 1994, regarding the following:

" NRC Inspection Report 94-04

" Root Cause Evaluations N0001795 and N0001947 Original Commitment "PG&E agrees with the violation as stated in the inspection report, in that there were instances of Technical and Ecological Services (TES) and Nuclear Power Generation (NPG) not performing Radiological Environmental Monitoring Program (REMP) work in accordance with approved procedures.

PG&E agrees that the quality of the REMP procedures can be enhanced.

{as such, the following changes were made:}

-TES: procedure E-1 has been enhanced to specify the alpha efficiency methodology to be used. Procedure E-1 also was enhanced to clarify that net counts per minute should be used for efficiency calculations. In addition, procedure E-1 has been revised to allow performance of hand calculations for efficiency calibrations.

- TES: procedure E-10 has been enhanced to provide more specificity regarding the yttrium precipitation methodology.

- IDAP CY1 .ID1 identifies DCPP site quality control as the new group responsible for evaluating the analytical results and preparing subsequent reports. TES will issue an action request (AR) in the plant Information management system (PIMS), which will allow DCPP site QC to track the cross-check program samples.

-TES: has revised its quality program (procedure 14.0, "Problems and Nonconformances," effective April 25, 1994) to confirm the AR initiation system, as it is implemented at DCPP.

-TES: Procedure C-4 will be revised by august 20, 1994, to allow additional flexibility. The required number of counts after the knee of the plateau at least 10,000. The user will use the source designated by the Health Physicist to be appropriate for plateau determination."

Revised Commitment This commitment was deleted.

Justification for Change This commitment was written in response to a 1994 NOV citing instances where TES and NPG REMP work was not performed in accordance with approved procedures. Technical and Land Services (TLS, the former TES) 4

Enclosure PG&E Letter DCL-07-034 no longer provides radiological support services; therefore, the commitment serves no function. Such services are now provided by qualified vendors that meet these standards.

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